Box 3 in Limbo: What the Netherlands’ Stalled Wealth-Tax Reform Means for Your Savings

July 2026

By Will Glyn

There’s a particular conversation I keep having with clients in the Netherlands. It usually starts with a tax assessment landing on the doormat, continues through “but I didn’t sell anything”, and ends with some version of: how can I owe tax on a return I never made?

Welcome to Box 3 — the Dutch system for taxing savings and investments, and one of the last in Europe still built around a return the government assumes you earned rather than the one you actually made. It has been fought over in the courts for years, it is halfway through being replaced, and at the end of June the upper house of parliament shelved the vote on that replacement altogether — leaving the project stalled and the current system running on for at least another two years.

One thing before we go further: Proctor Wealth Associates are financial planners, not tax advisers, and this article is education rather than tax advice — your own position needs a qualified Dutch tax professional. We work alongside Dutch tax advisers regularly and can put you in touch with one if you don’t already have somebody. But the planning consequences of Box 3 sit squarely in our world, and right now they are significant — especially for internationals whose protection from Box 3 runs out in January.

How Box 3 actually works in 2026

Box 3 doesn’t ask what your savings and investments actually earned. Instead, it looks at what you held on 1st January, sorts it into three categories, and assumes a fixed return on each: 1.28% on bank and savings balances, 6.00% on investments and other assets, and a 2.70% deduction rate on debts. That deemed income is then taxed at 36%. The first €59,357 per person is exempt — €118,714 for fiscal partners. One detail worth knowing: only the 6.00% is fixed. The savings and debt percentages are provisional and won’t be set definitively until early 2027, so a final bill can shift slightly from the one you estimate today.

A worked example makes it concrete. Suppose you’re single and hold €500,000 in funds and shares on 1st January 2026. After the allowance, €440,643 is in scope; the state assumes it earned 6.00%, or €26,439; and it taxes that assumed income at 36%. The bill: just over €9,500 — just under 2% of the entire portfolio, due whether markets rose, fell or went sideways.

It very nearly got worse. The original 2026 plan was to raise the deemed return on investments to 7.78% and cut the allowance to €51,396; parliament reversed both in an amendment late last year, landing on 6.00% and €59,357. One practical wrinkle survived: some early provisional assessments for 2026 were still calculated at the old 7.78% and are corrected in later assessments — if yours looked oddly high, that may be why. You can ask for a revised provisional assessment rather than wait; any difference is settled in the final 2026 assessment either way.

When you can pay on reality instead

Since last year there has been a formal escape hatch: the counter-evidence rule, or tegenbewijsregeling. If you can show your actual return was lower than the deemed one, you pay on the actual figure instead. For 2025 and 2026 that election is made inside the income tax return itself — the separate “Opgaaf werkelijk rendement” form only applies to 2024 and earlier, which trips up a lot of people reading older guidance.

The catch is that “actual return” is defined more broadly than most people expect. It includes unrealised gains — the rise in value of shares or property you still hold counts as return, even though you never sold and never saw the cash. Plenty of people who feel they had a poor year discover their paper gains put them above the deemed figure after all.

There’s a second catch that flatters the arithmetic if you miss it: the tax-free allowance does not apply to the actual-return calculation at all. The Supreme Court ruled it out. So you are comparing your total real return across every Box 3 asset against the total deemed figure — not measuring one against the 6.00% in isolation, and not getting €59,357 knocked off first.

The asymmetry is still worth knowing, though. If your real return beat the deemed one, the excess isn’t taxed; if it fell short, you can claim down to reality. In a genuinely bad year, that election is worth real money — which is why I’d treat checking it as an annual habit rather than a one-off.

The replacement that keeps not arriving

The long-promised successor is the Wet werkelijk rendement box 3 — a tax on actual returns, planned for 1st January 2028. The lower house passed it on 12th February this year. Then it reached the upper house, and stopped.

On 30th June the Senate shelved the vote altogether — not because the bill was defeated, but because it agreed to wait for an amending bill the government has promised. A week later, on 7th July, senators voted on a single motion stating they would have no objection to the bill being withdrawn, and rejected it; three further motions were held over without a vote. So the position today is genuinely suspended. Not passed, not withdrawn, not voted down.

Two separate things are now in motion. The near-term one is that amending bill, expected at Prinsjesdag in September alongside the 2027 budget, with a cabinet decision due in August — the softenings under discussion include cutting the headline rate from 36% to 35% and letting a loss in one year be carried back to the year before. The longer-term one, pushed by the lower house and written into the coalition agreement, is a possible redesign into a pure capital gains tax, charging profits when you sell rather than growth on paper. The Senate isn’t expected to pick the amending bill up until January.

My reading, for what it’s worth: plan on the system you have, not the one you’ve been promised. The deemed-return regime — plus the counter-evidence rule — may well be with us beyond 2028, whatever the official timetable says.

The shield expats are about to lose

Now the part that matters most if you moved to the Netherlands for work. For years, employees on the 30% ruling could elect “partial non-resident” status — which, in plain terms, kept their savings and investments outside the Netherlands out of Box 3. Dutch property and rights over it always stayed in scope — but a portfolio built up over a career abroad simply wasn’t the Dutch taxman’s business.

That election was abolished on 1st January 2025. Transitional rules protect those who already held the 30% ruling at the end of 2023 — but only until the end of this year, and only for as long as the ruling itself runs. If your 30% ruling expires part-way through 2026, the shield goes with it on that date. From 1st January 2027 partial non-resident status is gone for everyone, and every investment account, wherever in the world it sits, lands in Box 3 on that morning’s valuation.

Five months is not long, but it is enough to plan properly — and this is a planning window, not a reason to panic. How your assets are split between cash and investments, how allowances and fiscal partnership are used, how debts are positioned, and how foreign property and treaty reliefs interact with the Dutch rules all move the number meaningfully.

What I’d be doing before January

• Check which regime you’re in — still grandfathered under partial non-resident status, or already fully in Box 3? The answer changes everything about this year’s planning.
• Understand the 1st January snapshot — Box 3 is charged on what you hold on a single reference date. Be aware that switching between categories in the three months either side of it is specifically policed by the tax office; this is about planning ahead, not New Year’s Eve manoeuvres.
• Run the counter-evidence numbers — if your total actual return across all your Box 3 assets comes in below the total deemed figure, the rebuttal election may cut the bill. Remember there’s no tax-free allowance in that calculation, so it’s less generous than it first looks — but in a bad year it’s still worth real money.
• Mind the category mix — cash is deemed to earn 1.28%, investments 6.00%. The balance you genuinely want between them is a planning decision with a visible tax consequence.
• Map the cross-border pieces — foreign accounts, foreign property and double-tax treaties interact with Box 3 in ways generic guides gloss over. This is where internationals most often overpay, or misreport.

Where to go from here

If your savings and investments are caught by Box 3 — or will be from January — the sensible first step is a proper map of what you hold, where it sits, and in whose name. From there, the tax questions and the planning questions can each go to the right specialist.

That second part is where we come in, and it’s worth saying plainly: you don’t have to assemble the team yourself. We have established relationships with Dutch tax advisers and will introduce you to one suited to your circumstances — a straightforward introduction, with no obligation — then work alongside them on the financial-planning side, so the tax advice and the investment decisions are actually talking to each other.

If you’d like to start with the planning picture, or simply want pointing towards the right tax adviser, you can book a call with me.

This article is for informational purposes only and does not constitute tax advice. Box 3 figures shown relate to the 2026 tax year and are subject to change, and your position will depend on your personal circumstances. Always seek advice from a qualified Dutch tax adviser before acting.

Will is an Independent Financial Adviser with over a decade of experience helping expats make the most of their international status.